Aw geeze, those IAABO guys. What a bunch....
Silly monkeys.
It's too bad that that the late but unlamented Chuck Elias isn't still around. He's an IAABO rules interpreter. He could maybe run this one down and straighten it out. For the life of me, I can't see how anybody could possibly come up with a ruling like that. It literally ignores completely what the FED is saying.
Silly monkeys.